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PFAS Site InspectionA North Carolina Case Study

Presented by: Helen CorleyWood Environment & InfrastructureCharlotte, North Carolina Helen.corley@woodplc.com

Site Location

2 A presentation by Wood.

Case Study Location

Site Aerial

3 A presentation by Wood.

800 Acre Airport, close partnership with Air National Guard

• Requires once every five years EPA issue new list of no more than 30 unregulated contaminants to be monitored by public water systems– Third Unregulated Contaminant Monitoring Rule (UCMR3)

• Published May 2, 2012• (28 chemicals and two viruses)

– Included Six Perfluorinated Compounds• Drinking Water Health Advisory

– Published May 19, 2016

Environmental Protection Agency1996 Safe Drinking Water Act (SDWA)

4 A presentation by Wood. https://www.epa.gov/sites/production/files/2016-05/documents/ucmr3-factsheet-list1.pdf; https://www.epa.gov/ground-water-and-drinking-water/drinking-water-health-advisories-pfoa-and-pfos

Contaminant MRL* (µg/L)

Use or Source

perfluorooctanesulfonic acid (PFOS) 0.04 Surfactant or emulsifier; used in fire-fighting foam, circuit board etching acids, alkaline cleaners, floor polish, and as a pesticide active ingredient for insect bait traps; U.S. manufacture of PFOS phased out in 2002; however, PFOS still generated incidentally

perfluorooctanoic acid(PFOA)

0.02 Perfluorinated aliphatic carboxylic acid; used for its emulsifier and surfactant properties in or as fluoropolymers (such as Teflon), fire-fighting foams, cleaners, cosmetics, greases and lubricants, paints, polishes, adhesives and photographic films

perfluorononanoic acid (PFNA) 0.02

Manmade chemical; used in products to make them stain, grease, heat and water resistant

perfluorohexanesulfonic acid (PFHxS)

0.03

perfluoroheptanoic acid (PFHpA) 0.01

perfluorobutanesulfonic acid (PFBS) 0.09

Six Perfluorinated Compounds - UCMR3

5 A presentation by Wood. *minimum reporting level

PFAS – Increasing Attention

6 A presentation by Wood. https://pfas-1.itrcweb.org/wp-content/uploads/2017/11/pfas_fact_sheet_history_and_use__11_13_17.pdfOriginal source: J. Hale, Kleinfelder)

PFOA and PFOS Health Effects

7 A presentation by Wood. https://www.epa.gov/sites/production/files/2016-05/documents/pfoa_hesd_final_508.pdf; https://www.epa.gov/sites/production/files/2016-05/documents/pfos_hesd_final_508.pdf

U.S. Environmental Protection Agency. Health Effects Support Document for PFOS and Health Effects Support Document for PFOA. EPA Document Numbers 822-R-16-002 and 822-R-16-003; 2016.• “Human epidemiology data report associations between PFOA

exposure and high cholesterol, increased liver enzymes, decreased vaccination response, thyroid disorders, pregnancy-induced hypertension and preeclampsia, and cancer (testicular and kidney).”

• “Epidemiology data report associations between PFOS exposure and high cholesterol and reproductive and developmental parameters…. Data also suggest a correlation between higher PFOS levels and decreases in female fecundity and fertility, in addition to decreased body weights in offspring, and other measures of postnatal growth.”

• “PFOS is not readily eliminated from humans as evidenced by the estimated average half-life values of 4.1–8.67 years.”

Central North Carolina Site

– Site Inspection (2017-2018 Wood)• Aqueous Film Forming Foam (AFFF) used at the site since

1993. Used in the Air Force since 1970.– Potential Release Locations (PRLs) where AFFF was

potentially discharged, stored and where Aircraft Rescue Fire Fighting (ARFF) vehicles were washed

Department of Defense – Air National GuardInstallation Restoration Program -> Environmental Restoration Program

8 A presentation by Wood. https://apps.dtic.mil/dtic/tr/fulltext/u2/a554432.pdf; https://www.afcec.af.mil/Portals/17/documents/Environment/PFOS-PFOA_Fact_Sheet.pdf

Aqueous Film Forming Foam – A Brief History

9 A presentation by Wood. https://theintercept.com/2018/02/10/firefighting-foam-afff-pfos-pfoa-epa/

The Navy began requiring vessels to carry AFFF in 1967 after 134 sailors died in a fire aboard the USS Forrestal

Charred wreckage on the deck of the USS Forrestal Photo: Bettmann Archive/Getty Images

Aqueous Film Forming Foam – A Brief History, cont.

10 A presentation by Wood. https://theintercept.com/2018/02/10/firefighting-foam-afff-pfos-pfoa-epa/; https://www.afcec.af.mil/Portals/17/documents/Environment/PFOS-PFOA_Fact_Sheet.pdf

Marines extinguishing a blaze during a live fire training exercise

• Developed with 3M and patented by the Navy in 1966

• Creates a thin layer over the surface of the fuel that smothers the flames and prevents release of vapor

• Most efficient extinguishing method for petroleum fires and is widely used across the firefighting industry including commercial airports

• Key Ingredient: fluorinated surfactants

Photo: Lance Cpl. Shawn Valosin/U.S.

Striker – The most innovative ARFF vehicle in the World

11 A presentation by Wood. http://www.oshkoshairport.com/arfftrucks/newstriker

Source: Oshkosh Airport Products

Aqueous Film Forming Foam – Impacts to Soil/Water

12 A presentation by Wood. https://pfas-1.itrcweb.org/wp-content/uploads/2017/11/pfas_fact_sheet_history_and_use__11_13_17.pdf

• Complex mixture of unidentified PFAS• Released through:

– Low volume releases during storage/transfer or equip. calibration

– Moderate volume release for apparatus testing

– Occasional high volume broadcast discharge for fire suppression/prevention

– Periodic high volume broadcast release for fire training

– Leaks from foam distribution piping between storage and pumping locations

• Thousands of gallons of foam solution may be applied during a given event

Release of Firefighting Foam (original source: Adapted from Figure by J. Hale, Kleinfelder)

Potential Release Locations of Aqueous Film Forming Foam

13 A presentation by Wood.

Project Preparation

14 A presentation by Wood.

Workplan1,000+ Pages

Quality Assurance Project Plan (QAPP)

850+ Pages

37 WorksheetsIncluding Planning,

SOP, Schedule

SOPsPFC Protocols, Well

Install, Field Sampling

PFC Protocol Conference calls with

Drilling Contractor

Field Forms 12+ Including PFC Protocol Checklist

Field Sampling Plan (FSP)

34 pages

Sample Locations Sample Methodology

HASP100+ Pages

Have SOPs designed to minimize false positive results: No Teflon in sampling pumps, equipment, or sample

containers

No Gore-Tex, Tyvek, waterproof clothing

Natural-based products for sunscreens, bug spray, personal care products

Use vegetable oil instead of standard drilling equipment grease

Adequate numbers of blanks to monitor contamination

Well planned & executed programs can avoid the problems.

Sampling Considerations

15 A presentation by Wood.

Overview of Analytical Methods

16

EPA Method 537

Developed for finished/treated drinking water

Modified EPA Method 537

Typically used by commercial laboratories

ASTM Method 7979-17

Analysis of environmental solids (soil, sediment, sludge)

ASTM Method D7968

Analysis of environmental waters (other than drinking water)

Specialty Analyses

Source Fingerprinting

Non-targeted methods to explore unknown compounds

Total Oxidizable Precursors (TOP) AssayA presentation by Wood.

Data Collection• No plastic clipboards, binders

or spiral hard cover notebooks• No adhesives (Post-it® Notes)• No waterproof field books

other than Rite-in-the-Rain® Products

• Utilize Tablets with specialty coded forms for digital data collection – Required additional training

17 A presentation by Wood.

Tablet Collected Data Examples

18 A presentation by Wood.

Daily PFC Protocol Checklist - Tailgate Meeting

19 A presentation by Wood.

Sampling Onsite Water

In order to decontaminate drilling and sampling equipment with “PFC free” water, the on-site domestic water source needed to be sampled for six PFC compounds prior to mobilization

20 A presentation by Wood.

Nitrile Gloves Worn Continuously

21 A presentation by Wood.

Bring plenty of Gloves!

Sample Locations

22 A presentation by Wood.

Background Sample

Well Installation utilizing a combination drill rig

23 A presentation by Wood.

Shallow rock depth required air rotary

Utilized Hand Auger to pre-dig

24 A presentation by Wood.

Utilities presented challenging sample locations

25 A presentation by Wood.

Surface Water was not present at Outfalls

• Interim Air Force Guidance and USEPA lifetime drinking water Health Advisories– PFOS and PFOA

• 0.07 µg/L in groundwater/surface water (combined with PFOA)

• 1,260 µg/kg in soil• 1,260 µg/kg in sediment

• NCDEQ Interim Maximum Allowable Concentration PFOA• 2 µg/L in groundwater

Standards for 2017-2018 Site Inspections

26 A presentation by Wood.

Screening Criteria

27 A presentation by Wood.

Potential Release Locations of AFFF

28 A presentation by Wood.

Results – Fire Station

29 A presentation by Wood.

Results – Stormwater Outfalls

30 A presentation by Wood.

Results – Background

31 A presentation by Wood.

Recommendations• Additional Investigations to further evaluate concentrations of PFCs in

groundwater– Include source evaluation and delineation to determine nature and

extent of release• Although concentrations of PFCs in soil did not exceed the screening

criteria, they may be a source of PFCs to the groundwater– Additional soil investigation is recommended where groundwater

exceeded the Health Advisory

32 A presentation by Wood.

Wood – The basis for our lessons learned

33 A presentation by Wood.

Evaluating over 130 locations

globally

New technology pilot system

Policy development &

review

Fingerprinting and source

identification

Design/ constructio

n of Mitigation Systems

Strategic R&D Partnerships

Established Audit program

Authorof Industry BMP

documents

Canada, US, UK, Australia, Germany

Litigation support

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